Does a plaintiff have a loss of future earning ability as a result of her medical malpractice?

The plaintiff submits, relying in part on Heartt v. Royal, supra, that the plaintiff has established a loss of future earning ability. Counsel for the plaintiff relies in particular on the observation of Dorgan J. at p. 6 of that judgment where she stated as follows: Persons such as the plaintiff, without advanced education or training, more often than not must rely on robust physical health to earn a living. Occupations that require sustained sitting, repetitive use of upper limbs, or are physically demanding, are not now open to the plaintiff, limiting her future options if her present employment should cease. I am satisfied that as a physically limited person, without formal advanced training or education, the plaintiff is particularly vulnerable to the vagaries of the workplace from now until age 65 and will likely experience periods of unemployment, with the real possibility that they will be prolonged.